onboarding: are online and offline data getting married? · 2015-03-02 · acme loyalty member ken...
TRANSCRIPT
Onboarding: Are Online and
Offline Data Getting Married?
IAPP GLOBAL PRIVACY SUMMIT
MARCH 5, 2015
Sheila Colclasure, Acxiom
Noga Rosenthal, NAI
Ken Dreifach, ZwillGen PLLC
State of the Market History of Data and Privacy
• Top of Mind for Decades • Active collection • Consent based uses • PII and Aggregate • Batch enabled • Industry way ahead of regulation
Big Data = Big Changes • Volume, Velocity, Variety and Analytics • PII, DII, Pseudo-anonymous, De-identified • Passive vs active collection and sharing • Definition of “sensitive data” evolving and new harms • Offline to Online = Connection
Need to reach Audiences Digitally
How Does Onboarding Work?
3
CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
How Does Onboarding Work?
4
CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
How Does Onboarding Work?
5
CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
How Does Onboarding Work?
6
CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
How Does Onboarding Work?
7
CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
How Does Onboarding Work?
8
CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
PII vs. Anonymous - Definitions
Device Identifiable Information
Anonymous
Choice
X
De-Identified Information
X Personally Identifiable Information
Aggregate Information
Pseudo- anonymous
/ /
Personal Pseudo-
anonymous
PII DII AGI De-ID
SANI
ANI PII SANI
Covered Information
Ease of Technical Re-identification 100% 0%
What is Hashing?
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[email protected] Email run through Algorithm
43307bb5a669b247270a4d81cce6f3ff
[email protected] Email run through Algorithm
56699cc2f770d026374e2e9eccl925tg
[email protected] Email run through Algorithm
765fh9ku40ldne2f302mjnf983yyh76h
[email protected] Email run through Algorithm
12h7ufko0epmn678hfy549ldmn9853kl
Use of Hashing for Onboarding
11
Email run through Algorithm
43307bb5a669b247270a4d81cce6f3ff
Email run through Algorithm
56699cc2f770d026374e2e9eccl925tg
765fh9ku40ldne2f302mjnf983yyh76h
12h7ufko0epmn678hfy549ldmn9853kl
Privacy Framework for Onboarding
Ecosystem
Best Practices
Data
Best Practices
ONLINE OFFLINE
How Does Onboarding Enable Marketing?
• Did (hashed) Ken see the Acme ad?
• Did (aggregated) Ken buy an Acme product?
• Can/should we send (anonymous) Ken another ad?
• Or did Ken opt-out (of all ads)?
• What other consumers look like Ken (“lookalike” modeling)? • Based on offline, demographic, transactional
data?
13
Summary of Privacy Protections
• Reliable Sources: Notice At Point of Data Collection • Notice: Ensure that users are provided appropriate
notice concerning the collection and use of data for Interest-Based Advertising: • at the “match point” website sending hashed data • on the onboarding partner’s site (e.g, NAI member).
• Choice: Opt-Out • Non-association of non-PII with PII • Use of Hash Scripts
• No passage of (readable) PII from publisher
• Contractual enforcement
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Non-Merger of PII + Non-PII
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CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
Non-Merger of PII + Non-PII
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= HASH
TRIGGER
No Data Merge
Ken appears online. Cookie is placed on Ken’s
browser with Acme CRM data.
Avoid Re-identification
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CRM Data
Ken at One Main St. = Acme Loyalty Member
Ken = [email protected]
= HASH of [email protected]
Ken appears online. Cookie is placed on Ken’s browser with
Acme CRM data.
Cookie is redirected to Acme’s DMP.
Acme sends Ken an ad for new Acme widgets.
Offline Analytics
Avoid Re-identification
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Acme Ad to Ken for Widget
Match back to Offline
Behavior/PII
No OBA Data
Online-Offline Marriage: Backstory . . .
19
NOVEMBER 1999
Forward to 2015: NAI Code
The 2013 NAI Code defines Interest-Based Advertising (“IBA”) as
“the collection of data across web domains owned or operated by different entities for the purpose of delivering advertising based on preferences or interests known or inferred from the data collected.”
This provision covers data that is collected on one domain for use on another domain owned or operated by another entity for the purpose of delivering advertising based on known or inferred preferences.
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Onboarding Notice & Choice
NOTICE Access to Integrated Online Notice & Choice Platforms
• Notice via Match Partner sites
• Notice via DAA/NAI Sites: Ubiquitous “Enhanced” Notice
CHOICE Multi-channel Opt-Out (NAI, DAA)
• Linked from Match Partner Sites
• Linked from Trillions of Ads Each Month
DAA AboutAds.info
Opt-Out Channel: NAI Opt-Out Page
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Onboarding Opt-Out Permanence
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Onboarded Data: Reliable Sources Rule
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Strict Rules For
“Sensitive” Data
(NAI Code)
Sexual Orientation
Precise, Serious Health Condition
Sensitive Data Evolving: New Harms
Historically Sensitive Commercial Data » Identification, Financial. Medical, Children
•New Categories of Sensitive Commercial Data
» Precise geo-location
» At-risk populations (children & elderly) » Teens – 0-12, 13-17
» Elderly = over 60
» Social network information (public & non-public)
» Biometrics & Facial recognition
» Modeled Data
Traditional Harm » Financial, Physical
New Harms » Social Harms, Emotional, Reputational
Finances
Identification
Medical
Social Networks
Biometrics
At Risk Populations
Facial Recognition
Location
Onboarded Data: Reliable Sources Rule
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Follow Other
Data Rules!
Voter Registration Data
Kids’ Data
Credit Data
HIPAA
VPPA
Privacy Policies + “Reliable Sources”
Data Rules: How “Sensitive” is Too Sensitive?
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EU vs. US
• EU Sensitive Data = Political, Ethnicity, Religion, Race, Sex Life, Health,
• US Sensitive Data = “Sensitive” per NAI
• FTC and U.S. Senate Commerce Committee Data Broker Report (Dec. 2013, May 2014)
Questions?
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